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31. Prompt Disclosure. Respondent fully disclosed the violations to EPA within 21 days <br /> after it discovered the violations had, or may have, occurred. The violations were <br /> discovered on November 29,2007,and were reported to EPA in a letter dated December <br /> 14, 2007. <br /> 32. Discovery and Disclosure Independent of Government or Third Party Plaintiff. <br /> Respondent discovered and disclosed the violations to EPA prior to any federal, state, or <br /> local agency inspection or investigation,notice of citizen suit,the filing of a third-party <br /> complaint,the reporting of the violations by a"whistle-blower,"or imminent discovery <br /> by a regulatory agency. <br /> 33. Correction and Remediation. Respondent submitted to the EPA Risk Management Plan <br /> Reporting Center on November 29,2007. The disclosed violation did not cause any <br /> environmental or human harm. <br /> 34. Prevent Recurrence. Respondent has told EPA that it plans to take the following steps to <br /> prevent a recurrence of any violation of Section 112(r)(7) of CAA, 42 U.S.C. <br /> § 7412(r)(7): Respondent has revised its compliance management system procedures to <br /> include reporting requirements and updates for EPA's RMP regulations. Respondent will <br /> review all areas of environmental compliance at this and all other facilities it owns or <br /> operates. <br /> 35.. No Repeat Violations. Respondent has not had any other occurrence of these specific <br /> violations at the Facility within the past three years or at any other facility owned or <br /> operated by Respondent within the past five years. <br /> 7 <br /> CA/70 Provena Foods,dba Swiss American Sausage Co.,Lathrop,CA <br />